Where reductions for a guilty plea and assistance to authorities are not challenged as excessive, the proper focus on a sentence appeal is the notional starting point, not the sentence actually imposed. A starting point of 12 years for importation of approximately 242 grams of pure heroin by a courier is at the top of, but within, the available range. Caution is required in relying on sentencing precedents decided under the Customs Act 1901 regime or before the repeal of s 16G of the Crimes Act 1914 (Cth).
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